Environment Improvement Program

Pursuant to requirements under the Environment Protection Act 1993

Nyrstar Port Pirie Pty Ltd Ellen Street, Port Pirie SA 5540 EPA Authorisation Number 775

Prepared by Nyrstar Port Pirie Pty Ltd

November 2020

Environment Improvement Program for Lead Emissions to Air

Version History

Rev Revision Description By Whom Date 0 Issued for Use Rachel O’Halloran 30/11/20 1 Issued for EPA Review and Acceptance Rachel O’Halloran 15/12/20 2 Issued for Signing Rachel O’Halloran 22/12/20

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1 Tracking and Reference Information

Licensee Nyrstar Port Pirie Pty Ltd EPA Authorisation Number 775 Site to which this EIP applies The premises address is Ellen Street, PORT PIRIE SOUTH, SA, 5540 The registered address is Risdon Road, LUTANA TAS 7009

PREMISES: the whole of the land comprised in Titles Register – Certificate of Title, Crown Lease and Crown Record:

CT5372/307 CT5372/141 CT5832/215 CT6114/6 CT5861/76 CT6114/4 CT6114/1 CT 6126/838 CT6167/720 CT6167/721 CT6167/720 CT6167/722 CT6186/365 CL6204/175 Document produced by Nyrstar Port Pirie Pty Ltd

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2 General Description

2.1 Brief

Nyrstar Port Pirie Pty Ltd (Nyrstar) operates an integrated multi-metal smelter and refinery with flexibility to efficiently process a wide range of metals containing lead-dominant feedstock to produce refined lead, silver dore, zinc, copper and gold along with sulphuric acid. Nyrstar has owned and operated the facilities since 1 September 2007; however smelting activities have been conducted at the site since 1889.

Nyrstar is licensed under the Environment Protection Act 1993 to conduct the following activities at the site (EPA 775):

Activity ID Activity Description 1(1) Chemical storage and warehousing facilities 1(2)(a)(i) Chemical works (inorganic) 2(7) Ferrous and non-ferrous metal melting works 2(8) Metallurgical works 3(2)(b) Scrap metal treatment works 3(2)(e) Any other waste reprocessing facility 3(3)(a) Landfill Depot 3(5)(a) Activity producing listed waste 7(1) Bulk shipping facilities 7(3)(c) Crushing, grinding or milling works (rock, ores or minerals) 8(2)(a) Fuel burning coal or wood 8(2)(a) Fuel burning not coal or wood 8(6a)(a) Desalination plant that discharges wastewater to the marine environment 8(7) Discharges to marine or inland waters

2.2 Environmental Authorisation Compliance

This Environmental Improvement Program (EIP) is a requirement of Nyrstar’s environmental authorisation (EPA 775). The conditions of the licence issued to Nyrstar requiring the development of and compliance with an EIP (EPA 775, condition U-1191) states:

3.12 ENVIRONMENT IMPROVEMENT PROGRAMME NYRSTAR (U - 1191)

The Licensee must:

3.12.1 develop and submit to the EPA an Environment Improvement Programme (EIP) to the satisfaction of the EPA by the date listed below;

3.12.2 undertake public consultation in the course of developing the EIP;

3.12.3 ensure that the EIP includes, but is not limited to:

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a. summary of the results of public consultation undertaken in developing the EIP; b. details of actions, timeframes and milestones to be undertaken by the Licensee to minimise lead in air emissions from the Premises supported by a whole of Premises emissions inventory; c. details of actions, timeframes and milestones to be undertaken by the Licensee to minimise dust emissions (including fugitive emissions) at the Premises; d. details of actions, timeframes and milestones to be undertaken by the Licensee to prevent or minimise any environmental harm attributable to wastewater and contaminated stormwater management, including metals in wastewater and contaminated stormwater discharged via the 1M Flume and any leakage from the Sewage Lagoon; e. details of actions, timeframes and milestones to be undertaken by the Licensee to reduce litter and waste generation and/or disposal; f. details of actions, timeframes and milestones to be undertaken by the Licensee to prevent or minimise any environmental harm attributable to legacy plant, equipment and waste and to undertake progressive rehabilitation of legacy plant, equipment and waste; g. a methodology and framework for reporting to the EPA, including frequency, to demonstrate progress and completion of EIP compliance actions; h. a methodology and framework to assess the effectiveness of the actions detailed in the EIP; i. a methodology and framework to review and revise the EIP and actions, timeframes and milestones based on an analysis of emissions monitoring and management; and j. a methodology and framework for providing public access to the EIP, and to quarterly and annual reporting.

2.3 Referenced Documentation

In developing this EIP, Nyrstar has considered these other relevant documents: • National Environment Protection (Ambient Air Quality) Measure; • Environment Protection Act, 1993; and • Environment Protection (Air Quality) Policy, 2016. • Nyrstar Port Pirie Pty Ltd, Environmental Improvement Program for Lead Emissions to Air’ – dated 30 May 2014, Version 8, Revision 3 • Nyrstar Port Pirie Pty Ltd, Environmental Improvement Program for Lead Emissions to Air’, 2020 Version C, dated 25/09/2020

2.4 Intent

The intent of this EIP is to drive improvements at the Nyrstar Port Pirie site to ensure Nyrstar meets compliance requirements required by the Environment Protection Act 1993 and Nyrstar’s environmental authorisation (EPA 775). The target areas for improvement include but are not limited to:

• dust emissions (including fugitive emissions)

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• wastewater and contaminated stormwater management, including metals in wastewater and contaminated stormwater discharged via the 1M Flume and any leakage from the Sewage Lagoon • legacy plant, equipment and waste and to undertake progressive rehabilitation of legacy plant, equipment and waste • litter and waste generation and/or disposal

2.5 Site Map

Figure 1 shows a site aerial photograph of the Nyrstar Port Pirie site taken in 2018.

Figure 1 Site Aerial Photo (c2018) – Whole site.

Figure 2 shows a site map of the main operational area of the site and includes details of the buildings and roads. The site aerial photograph is included under the image to assist with identification of the identified locations.

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Environment Improvement Program for Lead Emissions to Air

3 Intended Approach

This EIP includes projects and actions that have been identified to meet the objectives listed in Section 2.4 of this document and to address the specific outcomes listed in EPA 775 Condition (U - 1191) 3.12.3 (b) to (f). The selection of projects listed in Section 3.4 and the subsequent compliance actions included in Section 5 have been based on, but is not limited to, the site’s Emission Inventory. The inventory used for this EIP has been developed utilising an updated version of Nyrstar’s NPI model, the planned plant operating times from the FY2021 production plan and qualitative assessment of emissions sources where estimating guidelines are unavailable or deemed to incorrectly estimate emission rates of known sources located within the facility. A copy of the emission inventory is included in Appendix 1 and also provides an index from the emission source to the corresponding EIP project. A location map showing the emission source linked to the Source ID is also included in Appendix 1 for reference.

A project has also been included to drive continuous improvement of the emissions inventory over time. This will include, but may not be limited to, incorporating updates in the inventory based on investigations and evaluations completed in the development of this EIP.

The EIP projects have been selected to target elimination or reduction of uncontrolled emission sources and/or transport mechanisms.

Section 5 provides the details of actions, timeframes and milestones to be undertaken by Nyrstar to drive improvements in environmental performance and prevent or minimise environmental harm in compliance with Nyrstar’s environmental authorisation EPA 775 Condition (U - 1191) 3.12.3 (b) to (f). A general overview of these activities is summarised in Section 3.4.

3.1 Methodology and framework for reporting to the EPA

EPA 775 Condition (U - 1191) 3.12.3 (g) requires Nyrstar to provide a methodology and framework for reporting to the EPA, including frequency, to demonstrate progress and completion of EIP compliance actions.. Nyrstar will provide a written update outlining the status of compliance actions on a Quarterly and Annual basis. This frequency is determined on the basis that it is inherently required in EPA 775 Condition (U - 1191) 3.12.3 (j).

Nyrstar will also provide completion reports outlining details confirming completion of actions.

3.2 Methodology and framework to assess the effectiveness of the actions detailed in the EIP

EPA 775 Condition (U - 1191) 3.12.3 (h) requires Nyrstar to provide a methodology and framework to assess the effectiveness of the actions detailed in the EIP.

Individual key performances indicators (KPI’s) will be established for each of the Compliance Actions included in Section 5 that will be measured to determine effectiveness of the proposed actions in achieving intended outcomes. Performance baselines will be established prior to implementation of the

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action. Subsequently, the identified performance indicators will be used to show the extent to which the intended outcomes are achieved when compared to the baseline.

Additionally, Nyrstar will also review performance against the overarching site environment outcomes e.g. community lead in air results or 1M Flume water quality results etc. This review will also be used in the assessment of action effectiveness on the intended environmental outcome and whether additional steps or new actions are required. Outcomes of these reviews will be used to update and further refine the site’s Emission Inventory.

3.3 Methodology and framework to review and revise the EIP and actions, timeframes and milestones based on an analysis of emissions monitoring and management

EPA 775 Condition (U - 1191) 3.12.3 (i) requires Nyrstar to provide a methodology and framework to review and revise the EIP and actions, timeframes and milestones based on an analysis of emissions monitoring and management.

In the first instance, Nyrstar will comply with requirements of EPA 775 Condition (U-1204) 1.6 TSP LEAD 3 MONTH AVERAGE - TARGETS (U - 1204) which states:

1.6 TSP LEAD 3 MONTH AVERAGE - TARGETS (U - 1204)

The Licensee must:

1.6.1 take all reasonable and practicable measures to not exceed the following rolling 3 month average TSP Lead in Air Targets set out in this condition, beginning on 31 December 2020 using daily measurements and calculated on the final day of each month: a. 0.45 ug/m3 TSP Lead at the Licensee’s Oliver St and Pirie West Primary School Monitoring Stations; b. 2.2 ug/m3 TSP Lead at the Licensee’s Ellen Street Monitoring Station; and c. 1.0 ug/m3 TSP Lead at the Licensee’s Boat Ramp Monitoring Station;

1.6.2 where a rolling 3 month average TSP Lead in Air Target is exceeded: a. provide public notification and notification to the EPA within 72 hours of laboratory confirmation of the Target exceedance; b. provide a summary report to the EPA within 5 business days of the Target exceedance, detailing: I. the measured lead in air over the averaging period; II. details of any identified reason(s) for the exceedance; and III. details of any remedial action to be implemented to eliminate future occurrences of the Target being exceeded

This will drive ongoing improvement of the site’s Lead in Air performance.

Nyrstar will also hold quarterly and annual review in conjunction with the EPA to review and revise the EIP and actions, timeframes and milestones based on an analysis of overall emissions monitoring and management.

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Environment Improvement Program for Lead Emissions to Air

4 Public Consultation

In developing this EIP, Nyrstar completed public consultation in compliance with Nyrstar’s environmental authorisation EPA 775 Condition (U - 1191) 3.12.3 (j) . Information on the proposed EIP and how to provide submissions was included in The Port Pirie Recorder (local newspaper), on the Nyrstar Port Pirie Community Consultation webpage (http://nyrstarportpirie.com.au/), and via the Nyrstar Port Pirie Facebook page. Details of information included in each of these forums and the webpages on the website are included in Appendix 2 for reference.

Submissions were to be addressed to the Environment Team ([email protected]) via links on the EIP webpage.

Input from the EPA is solicited through the document review process prior to finalisation of the EIP.

At the end of the nominated consultation period (17 September - 23 October 2020), no feedback had been received.

4.1 Public Access to EIP and reporting results

EPA 775 Condition (U - 1191), Clause 3.12.3 (j), also requires that Nyrstar provide a methodology and framework for providing public access to the EIP, and to quarterly and annual reporting. Nyrstar will utilise the Nyrstar Community Consultation webpage (http://nyrstarportpirie.com.au/) to make the EIP available to the public. This page will also be utilised to provide a point of accessibility to Quarterly and annual reporting upon request. The Nyrstar Port Pirie Facebook page will be used to alert followers to these updates at the time of posting.

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Environment Improvement Program for Lead Emissions to Air

Appendix 1 Emission Inventory

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Environment Improvement Program for Lead Emissions to Air

Figure 3 Emission to Air By Category Type

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Figure 4 Emission to Air By Category Type- Main Plant Area

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Appendix 2 Nyrstar EIP Communication and Community

Page38of38 Nyrstar EIP Communication and Community Consultation

Recorder Nyrstar is developing an Environmental Improvement Programme (EIP). As part of this process, Nyrstar would like to engage the community in the development of this EIP. Suggestions from the community for projects that could be considered to assist in reducing emissions of lead to air, metals to wastewater, groundwater impacts and improve the site amenity are welcomed. While Nyrstar is open to receiving suggestions as part of the EIP engagement process, it reserves the right to consider or reject any suggestions received. Submissions can be made to Nyrstar on our website http://nyrstarportpirie.com.au/ by 23rd October 2020.

Webpage Notification Nyrstar is developing an Environmental Improvement Programme (EIP). As part of this process, Nyrstar would like to engage the community in the development of this EIP. Suggestions from the community for projects that could be considered to assist in reducing emissions of lead to air, metals to wastewater, groundwater impacts and site amenity are welcomed. While Nyrstar is open to receiving suggestions as part of the EIP engagement process, it reserves the right to consider or reject any suggestions received. A copy of the draft EIP is available from the Nyrstar Port Pirie Environment team [email protected]. Please contact us for further information and with suggestions for the EIP by 23rd October 2020.

To complete our communication and community consultation program, the following updated schedule is proposed.

• 6th October project list finalised for communication overview document • 14th October: Publicly communicate on webpage and in Recorder and request email submissions to Environment Team. • 23rd October: Finalise EIP • 1st November: Submit finalised draft to the EPA • 30th November: Formal EIP in place

Nyrstar’s key Environmental Improvement Projects (EIP) projects fall under four sub-headings;

Nyrstar Air Quality Management Strategy - Lead in Air Projects Management of air quality is a priority for Nyrstar as a key environmental aspect requiring ongoing operational monitoring and management to ensure Nyrstar continues to meet its legal obligations, expectations of the community and corporate quality standards.

The primary objectives of the Nyrstar Air Quality Management Strategy are to;

• Reduce the potential for adverse impacts on the community and the environment from emissions to air of lead, sulphur compounds and particulates. • Manage and monitor emissions to air including lead, sulphur compounds and particulates. • Reduce fugitive emissions of particulates from the site.

The ongoing reduction of lead in air is a key focus area for the business and its new licence to operate which has reduced parameters. As part of Nyrstar’s EIP, numerous projects to achieve the longer term requirements of the new reduced licence limit targets have been, or will commence in coming months. Some of these new projects include (but are not limited to);

Nyrstar EIP Communication and Community Consultation

• Installation of a purpose designed chute at the caster tip-end of the Top Submerged Lance (TSL) to capture slag blocks and reduce impact damage, emissions and double handling, • Installation of a new environmental hopper on the wharf to reduce emissions generated by loading/unloading activities and • Installation of an upgraded wheel wash for all vehicles leaving the site to reduce the transmission of contaminated lead bearing material leaving the site and being transported into the community via road.

Suggestions from the community for projects that could be considered to assist in further reducing emissions of lead to air are welcomed. While Nyrstar is open to receiving external suggestions as part of the EIP engagement process, it reserves the right to consider or reject any suggestions received.

Nyrstar Ground Water Management Strategy – Ground Water Projects

This strategy addresses ground water issues related to the long-term operation of the Nyrstar Port Pirie Smelter. Achievement of the objectives of this strategy are closely linked with the Voluntary Site Contamination Assessment Proposal (VSCAP) which was developed with and approved by the EPA and the accredited Site Contamination Auditor.

Some of the primary objectives of the Nyrstar Ground Water Management Strategy include;

• Reduce potential ongoing impacts and sources of groundwater that have the potential to affect off-site receptors through a program of improving operations and reducing the overall environmental impact of the site and • Obtain robust information on groundwater quality and movement.

Better management of potential impacts on groundwater quality is a priority for Nyrstar and as such, Nyrstar has been undertaking parallel programs of improving site operations by reducing or removing potential ongoing sources and employing a site characterisation and remediation program to address potential risks.

As part of Nyrstar’s EIP, numerous projects to achieve the longer term requirements of the new reduced licence limit targets have been, or will commence in coming months. Some of these new projects include (but are not limited to);

• Upgrade containment in the Sewage Treatment Plant • Demolition of the existing copper plant organic sump and the installation of a new pre-cast sump and • Resurfacing of the wharf’s Berth 8 in parallel with reprofiling the front 18 metres of Berth 8 and Berth 9 to prevent surface water runoff into the Port Pirie River.

Suggestions from the community for projects that could be considered to assist further improve Nyrstar’s ground water management are welcomed. While Nyrstar is open to receiving external suggestions as part of the EIP engagement process, it reserves the right to consider or reject any suggestions received.

Nyrstar EIP Communication and Community Consultation

Surface Water Quality Management Strategy - Wastewater Metals Projects

This strategy addresses surface water quality issues related to the operation of the Nyrstar Port Pirie Smelter. The smelter is in close proximity to sensitive receptors and as it is within the Port Pirie River catchment, much of the natural drainage from the site is directed to the Port Pirie River and parts of the western most portion of the smelter naturally drain to Spencer Gulf. The site run off is collected in a stormwater system that drains to a sedimentation pond to minimise contaminates entering the environment by settling out solids. The water from the sedimentation pond discharges via First creek to Spencer Gulf and is monitored by the EPA via licence conditions.

Some of the primary objectives of the Nyrstar Surface Water Quality Management Strategy include;

• Reduce potential impacts on the marine and fresh water environments • Improve materials handling and storage to reduce the risk of potentially contaminated runoff and • Manage the quality of surface water discharge from the sedimentation pond to reduce the risk of adverse impact to offsite surface water environments.

Surface water quality is a priority for Nyrstar and as such, ongoing operational management and monitoring measures will continue to be implemented.

• Purchase of new on site road sweepers to increase effectiveness and efficiencies with dust removal and • Resurfacing of site roads to significantly improve cleaning and remove fugitive dust.

Suggestions from the community for projects that could be considered to assist further improve Nyrstar’s waste water management are welcomed. While Nyrstar is open to receiving external suggestions as part of the EIP engagement process, it reserves the right to consider or reject any suggestions received.

Natural Resources Management Strategy - Waste and Demolition Projects This strategy addresses Natural Resources Management issues related to the operation of the Nyrstar Port Pirie Smelter. A specific focus area is regarding waste management (including in particular resource recovery and waste reduction) and how Nyrstar intends to manage on site waste according to the waste management hierarchy.

Additionally a key objective of the Natural Resources Management Strategy is to implement sustainability initiatives related to water, energy, vegetation, carbon emissions and waste. A key focus for the site is to ensure that all process and general waste generated by the operation is efficiently managed to ensure legal compliance, eco-efficiency, pollution prevention and a high standard of site aesthetics.

Nyrstar EIP Communication and Community Consultation

• The commissioning of a new site waste facility. • Processing and recycling 12,000 tonnes of concrete and 1,000 tonnes of site black sand to construct 2,500 concrete blocks (each weighing 1.2 tonnes) for bunker construction, the recycled concrete in combination with black sand will also be used on site for road base • The demolition of 8 redundant/old buildings on site at a cost of approximately AUD 2M in 2021, starting with the old acid plant.

Nyrstar will continue to focus on reducing its environmental footprint through the recycling of site waste. From October 2019 to September 2020 the site recycled 2,001 tonnes of scrap metal, 24 tonnes of paper (as a paper mache dust suppressant to stockpiles), 4.3 tonnes (approximately 178,000) bottles and cans, 29 tonnes of carboard, 143 kl of waste oil and 14.9 tonnes blue booties (overshoes to minimise exposure) to energy recovery.

Suggestions from the community for projects that could be considered to assist further improve Nyrstar’s waste and demolition management are welcomed. While Nyrstar is open to receiving external suggestions as part of the EIP engagement process, it reserves the right to consider or reject any suggestions received.